128 RADIOLOGICAL CLEANUP OF ENEWETAK ATOLL and minimize the volume of soil excised. Possible disadvantages were the limited soil depth which the system would survey andthe possibility that this new approach might not be acceptable to EPA and other concerned agencies. A prototype in situ detector was undergoing tests at the site of the Hamilton event on the Nevada Test Site, and it was anticipated that ERDA would approve the system for use at Enewetak.3?! . The Radiological Cieanup Plan was revised again on 16 July 1976, but it left some basic questions relative to radiological cleanup criteria still unanswered. Field Command asked for HQ DNA assistance in obtaining definitive answers from ERDA assoon as possible.392.303 Detailed criteria and guidance were required to complete a Radiological Cleanup Appendix to the CONPLAN34 and to develop estimates of work requirements upon which to base resource needs. The situation was complicated by two factors: (1) ERDA Headquarters in Washington had not formally assigned ERDA-NV the responsibility for furnishing radiological support, and (2) MILCONfunds were limited. The DNA-ERDA agreement stipulated that ERDA would provide technical and scientific advice and assistance on radiological activities associated with cleanup, including, but not limited to: a, Advice and assistance on the preparation of the radiological cleanup plan and the radiological safety program. b. Interface with other Federal agencies concerning radiological matters. c. Provision of on-atoll ERDA representation. d. Performance of radiological support, to include: (1) Day-to-day field ~j. monitoring, dosimetry, and record keeping for health andsafety. (2) Radiological classification of material for removal, disposal, or reuse. (3) Certification, on an island-by-island basis. (4) Establishment, operation, and maintenanceof a field laboratory. Item d of these ERDA commitments was contingent on reimbursement from DNA. In view of the $20 million ceiling which had been set by Congress and its charge to use all available economy measures, DNA 5 reimbursement to ERDA would of necessity be limited to the $1.5 million which had been estimated earlier. A compromise was reached whereby the military services would provide for radiological safety and the classification of debris and ERDA would only provide for classification of soil and management of the radiological laboratory. Field Command and ERDA-NV representatives conferred on 28-29 tore an-] military personnel. To reduce project costs further, it was agreed that military technicians would assist in the ERDA contractor laboratory, in driving the in situ vans, and in maintaining and repairing radiation detectors and other equipment. ERDA-NV representatives advised that their radiological support would not be available in April 1977, as was Planning and Programming 129 required to meet the then-planned | March 1977 D-Day. They estimated it would require 6 to 9 months; i.e., until | October 1977, before the radiological laboratory would be operational.35 The major technical problem in completing the radiological cleanup plan concerned criteria for evaluating debris and soil against radiological cleanup requirements. Without adequate crileria, the type of equipment needed for field and laboratory measurements was uncertain, necessary survey procedures could not be developed, and there was no measure for determining and certifying the quality of cleanup. The need for precise criteria for the cleanup project was made even morecritical by the planned periodic rotation of personne! throughout the life of the project. The AEC Task Group had made recommendations on cleanup of both debris and soil, but these recommendations were too general and open to foo many interpretations to serve as criteria for those in the field. With respect to debris, the AEC Task Group had recommended that ‘all radioactive scrap metal and contaminated debris. Should be removed."°3%6 This recommendation was modified in the EIS Case 3 cleanup actions to the requirement that ‘‘radioactive scrap be removed from all islands in the atoll.”’ Although this guidance might seem clear-cut at first glance, that was not the case. No material is totally devoid of radioactivity; and clearly not every level of radioactivity is sufficient to warrant disposal of the material containing it. The ERDA radiological advisors to DNA on the Enewetak Cleanup were reluctant to recommend criteria for use in deciding which debris was radioactive and deserving of disposal and which was not. ERDA had criteria in existence governing the release of matcrials for uncontrolled use following use in contaminated areas, but these criteria were not Suitable for the Enewetak debris situation. One reason was that much of the Enewetak debris was situated in areas with considerable backgro und radiation, so that definitive measurements could not be made unless the debris were relocated to a low background area. Such a practice would have led to costly, unnecessary debris movement merely to make measurements. Numerous attempts were madeto define ‘“‘background”’ and situations when debris might qualify for disposal, but none were acceptable. A second reason why ERDA criteria were not suitable was that they only addressed surface contamination. Normally, activate d contamination suchas that found in much of the Enewetak debris was not oncoem re rrureranons.Panning mecing on debris criteria, Mr. Tommy F. McCraw, of ERDA Headquarters, pointed out that ERDA’s reluctance to provide advice stemmed in part from the fact that they had not been successful in negotiating a contamination threshold level with EPA. He also felt that, if criteria were more Stringent than had been used at Bikini, the Bikinians would not understand. (Likewise, the